Copeland v. State
129 So. 3d 508
| Fla. Dist. Ct. App. | 2014Background
- Copeland appeals his first-degree murder conviction and life without parole sentence.
- He was 17 at the time of the shooting.
- The victim, Jearicka Mack, was 15 and a bystander at a club parking lot fight.
- Florida's 2012 capital felony statute, §775.082, allowed death or LWOP, but Miller v. Alabama restricts mandatory LWOP for juveniles.
- The trial court conducted an individualized mitigation inquiry and still imposed LWOP, which the court affirms as permissible following Washington v. State and related precedents.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a juvenile can be sentenced to LWOP under §775.082 after Miller. | Copeland argues Miller bars LWOP for juveniles. | State argues LWOP remains available with individualized mitigation as in Washington. | LWOP permissible with individualized mitigation; affirmed. |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (U.S. (2005)) (juvenile death penalty prohibited by Eighth Amendment)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. (2012)) (mandatory LWOP for juveniles unconstitutional)
- Washington v. State, 103 So.3d 917 (Fla. 1st DCA 2012) (LWOP permissible with mitigation inquiry under §775.082)
- Ortiz v. State, 119 So.3d 494 (Fla. 1st DCA 2013) (adopts Washington reasoning on LWOP)
- Hernandez v. State, 117 So.3d 778 (Fla. 3d DCA 2013) (supports mitigation-based LWOP analysis)